Re: EU Official Languages
I also wondered... the European Commission publishes the Official Journal of the European Communities in three languages, French, German and English. Why can't we? In a message dated 6/30/99 5:05:05 AM Pacific Daylight Time, s_doug...@ecrm.com writes: << We had several discussions about this issue. I presented to Engineering and Marketing the legal requirements from the directives and let them make the choice as to what languages we should actually use. In the end we decided to print in five languages - English, French, German, Spanish, Italian as a matter of course. Marketing came back with one special request to add either Swedish or Finnish, I can't remember which. We don't do any other languages. We have had no complaints as to what languages we either have or don't have. Except from our documentation people who have to make out the purchase requisitions for the translations which are very costly. Scott s_doug...@ecrm.com -Original Message- From: wo...@sensormatic.com [SMTP:wo...@sensormatic.com] Sent: Tuesday, June 29, 1999 1:44 PM To:emc-p...@majordomo.ieee.org Subject: EU Official Languages When a Directive requires information to be provided to the user, and that equipment is intended to marketed in every EU and EFTA country, what minimal set of languages must be used? I can think of the following languages that are used in these countries. Are there more languages that must be included? Can some of these be deleted? English, French, German, Spanish, Portuguese, Italian, Greek, Dutch, Danish, Swedish, Finnish, and Norwegian (EFTA) >> - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: RE: EU Official Languages
Bill, What you have said does not actually contradict my own statement (and maybe that wasn't your intention!). One must not confuse the requirement to draw the instructions up in one of the languages of the EU with that of then translating the instructions into the other languages for each territory in which the product is sold. Annex 1 section 1.7.4b of the Machinery Directive says: "The instructions must be drawn up in one of the Community languages by the manufacturer or his authorised representative established in the Community. On being put into service, all machinery must be accompanied by a translation of the instructions in the language or languages of the country in which the machinery is to be used and by the instructions in the original language. This translation must be done either by the manufacturer or his authorised representative established in the Community or by the person introducing the machinery into the language area in question. By way of derogation from this requirement, the maintenance instructions for use by specialised personnel employed by the manufacturer or his authorised representative established in the Community may be drawn up in only one of the Community languages understood by that personnel." What the directive is trying to achieve is a process whereby a complete and coherent set of instructions are created in a community language, and then are translated to be comprehensible to people in states with other languages. You only need one Declaration of Conformity, and this must be in the language in which the instructions were originally drafted. However, this does not mean that you only need to provide the user instructions in one language - it is very clear that every territory which has a different language will require the instructions to be translated accordingly. Quite what the EC hoped to achieve by requiring the instructions to be originally drafted in a community language is not made clear. I would guess the idea was that the structure and culture of the western European languages are sufficiently similar that so long as the instructions make good sense in one of them, they will still be useable in other languages even if they 'loose a bit' in translation. However, if one were to start from (for instance) a coherent document in Chinese, and translate to English one might end up with a document which was pretty well useless unless it's carefully re-written after translation. Regards Nick. At 09:29 -0400 1/7/99, Bill Somerfield wrote: >Please check the following : >Annex II of the Machinery Directive > A. Contents of the EC Declaration of conformity (1) > >(1) This declaration must be drawn up in the same language as the >instructions ( see Annex I, point 1.7.4) and must be either typwritten or >handwrittrn in block capitals. > > > - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: EU Official Languages
Certification type documentation such as Declarations of Conformity can be in any EU language. User documentation relating to safe use of the product MUST be in the language(s) of the country in which the product is being sold, although if the product has separate installation or maintainance instructions these can be in a language likely to be understood by appropriately trained personnel. This requirement is a function of the directives (most clearly elucidated in the Machinery Directive, but the principle applies to LVD and EMC, as well as all the other CE mark directives), independently of any requirements contained in harmonised standards. It's a fairly basic principle of criminal law (which this is) that you can't alter your legal obligations by contractual means, so I'm afraid that the basic premise of your approach is flawed. Sorry to say, but you may be living on borrowed time if you are not providing manuals in appropriate languages in all markets. It's also a basic principle of article 100a of the Treaty of Rome (which is the root of all CE-mark directives) that member states of the EU cannot oblige manufacturers of legitimately CE marked goods to meet any different or additional requirements to those laid out in the directives. The requirements of the national public safety law in Germany are required to be harmonised with those of all other EU member states - compliance with any additional requirements (such as any required for the application of certification/agency approval marks) is optional and, in this sense, has nothing to do with CE marking. The effect on your products is as you descibe, but the basis of the requirements is not. Nick. >Richard, > >I can only speak from my experience with the LVD and EMC directives. > >1) The requirement for CE marked products is that the user documentation and >the DoC be in "one" of the official languages of the EU. So, we use English >as one of the languages. > >2) That being said, the safety standards my company uses to comply with the >CE mark, require that we provide user documentation in any of the other >official languages if in fact our customer explicitly requires it by >contract. However this may be a reduced size document containing only those >portions that are specifically related to the safe installation, operation, >maintenance and disposal of the product. It is not required that you >translate sections like theory of operation, applications, sales literature, >etc. > >3) Additionally, when we certify a product through a notified body, in this >case LGA in Nurnberg Germany, the national public safety law requires a >manual in German. I suspect other nationalities within the EU have similar >requirements for certified products. > >This policy has been confirmed by our representative from LGA America. > >-doug > - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: EU Official Languages
It should be borne in mind that there may be certain national consumer laws which require user documentation to be in the national language. Dave Wilson EMC Manager BABT Product Service -- Original Text -- From: "POWELL, DOUG" , on 6/30/99 9:56 AM: Richard, I can only speak from my experience with the LVD and EMC directives. 1) The requirement for CE marked products is that the user documentation and the DoC be in "one" of the official languages of the EU. So, we use English as one of the languages. 2) That being said, the safety standards my company uses to comply with the CE mark, require that we provide user documentation in any of the other official languages if in fact our customer explicitly requires it by contract. However this may be a reduced size document containing only those portions that are specifically related to the safe installation, operation, maintenance and disposal of the product. It is not required that you translate sections like theory of operation, applications, sales literature, etc. 3) Additionally, when we certify a product through a notified body, in this case LGA in Nurnberg Germany, the national public safety law requires a manual in German. I suspect other nationalities within the EU have similar requirements for certified products. This policy has been confirmed by our representative from LGA America. -doug === Douglas E. Powell, Compliance Engineer Advanced Energy Industries, Inc. Fort Collins, Colorado 80525 USA === -Original Message- From: WOODS, RICHARD [mailto:wo...@sensormatic.com] Sent: Tuesday, June 29, 1999 11:44 AM To: 'emc-pstc' Subject: EU Official Languages When a Directive requires information to be provided to the user, and that equipment is intended to marketed in every EU and EFTA country, what minimal set of languages must be used? I can think of the following languages that are used in these countries. Are there more languages that must be included? Can some of these be deleted? English, French, German, Spanish, Portuguese, Italian, Greek, Dutch, Danish, Swedish, Finnish, and Norwegian (EFTA) - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: EU Official Languages
Richard, I can only speak from my experience with the LVD and EMC directives. 1) The requirement for CE marked products is that the user documentation and the DoC be in "one" of the official languages of the EU. So, we use English as one of the languages. 2) That being said, the safety standards my company uses to comply with the CE mark, require that we provide user documentation in any of the other official languages if in fact our customer explicitly requires it by contract. However this may be a reduced size document containing only those portions that are specifically related to the safe installation, operation, maintenance and disposal of the product. It is not required that you translate sections like theory of operation, applications, sales literature, etc. 3) Additionally, when we certify a product through a notified body, in this case LGA in Nurnberg Germany, the national public safety law requires a manual in German. I suspect other nationalities within the EU have similar requirements for certified products. This policy has been confirmed by our representative from LGA America. -doug === Douglas E. Powell, Compliance Engineer Advanced Energy Industries, Inc. Fort Collins, Colorado 80525 USA === -Original Message- From: WOODS, RICHARD [mailto:wo...@sensormatic.com] Sent: Tuesday, June 29, 1999 11:44 AM To: 'emc-pstc' Subject: EU Official Languages When a Directive requires information to be provided to the user, and that equipment is intended to marketed in every EU and EFTA country, what minimal set of languages must be used? I can think of the following languages that are used in these countries. Are there more languages that must be included? Can some of these be deleted? English, French, German, Spanish, Portuguese, Italian, Greek, Dutch, Danish, Swedish, Finnish, and Norwegian (EFTA) - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: EU Official Languages
We had several discussions about this issue. I presented to Engineering and Marketing the legal requirements from the directives and let them make the choice as to what languages we should actually use. In the end we decided to print in five languages - English, French, German, Spanish, Italian as a matter of course. Marketing came back with one special request to add either Swedish or Finnish, I can't remember which. We don't do any other languages. We have had no complaints as to what languages we either have or don't have. Except from our documentation people who have to make out the purchase requisitions for the translations which are very costly. Scott s_doug...@ecrm.com -Original Message- From: wo...@sensormatic.com [SMTP:wo...@sensormatic.com] Sent: Tuesday, June 29, 1999 1:44 PM To: emc-p...@majordomo.ieee.org Subject:EU Official Languages When a Directive requires information to be provided to the user, and that equipment is intended to marketed in every EU and EFTA country, what minimal set of languages must be used? I can think of the following languages that are used in these countries. Are there more languages that must be included? Can some of these be deleted? English, French, German, Spanish, Portuguese, Italian, Greek, Dutch, Danish, Swedish, Finnish, and Norwegian (EFTA) - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: EU Official Languages
Richard You may find that Swedish can be acceptable for the four Scandinavian countries plus Iceland. Chris Colgan EMC & Safety TAG McLaren Audio Ltd mailto:chris.col...@tagmclarenaudio.com > -Original Message- > From: WOODS, RICHARD [SMTP:wo...@sensormatic.com] > Sent: 29 June 1999 18:44 > To: 'emc-pstc' > Subject: EU Official Languages > > > When a Directive requires information to be provided to the user, and that > equipment is intended to marketed in every EU and EFTA country, what > minimal > set of languages must be used? I can think of the following languages that > are used in these countries. Are there more languages that must be > included? > Can some of these be deleted? > > English, French, German, Spanish, Portuguese, Italian, Greek, Dutch, > Danish, > Swedish, Finnish, and Norwegian (EFTA) > > - > This message is coming from the emc-pstc discussion list. > To cancel your subscription, send mail to majord...@ieee.org > with the single line: "unsubscribe emc-pstc" (without the > quotes). For help, send mail to ed.pr...@cubic.com, > jim_bac...@monarch.com, ri...@sdd.hp.com, or > roger.volgst...@compaq.com (the list administrators). > = Authorised on 06/30/99 at 09:01:55; code 37453441FFF928DE. - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
